Regulation of Dangerous Goods
Main ContentChapter 3.2 Packing
| 3.2.1 |
Legal Requirements |
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| 3.2.1.1 |
The packing requirements are stipulated in sections 2 to 7 of Schedule 6 of Cap. 295G which are replicated below:
2. S2DG must not be packed together with any other S2DG that is specified as incompatible in the code of practice.
3. S2DG packaging must be— (a) designed, made of appropriate materials and of a size, so as to be— (i) suitable for the packaging, having regard to the nature of the S2DG contained in it and the capability of withstanding ordinary risks during storage or conveyance; and (ii) able to protect the S2DG against inadvertent or accidental ignition or initiation during storage or conveyance; and (b) maintained in good condition and repair and free from corrosion, contamination or any other defect which may impair its performance.
4. S2DG packaging must be of a size specified in the code of practice, if applicable.
5. S2DG packaging must be filled in conformity with the filling ratio specified in the code of practice, if applicable.
6. S2DG packaging must be filled with S2DG to the extent as to leave within the packaging air space or ullage that is not less than the minimum air space or ullage specified in the code of practice, if applicable.
7. S2DG packaging must be tested according to a method specified in the code of practice, if applicable. |
| 3.2.2 | General Application |
| 3.2.2.1 | This chapter provides standards and guidelines on the packing of DG, except for Class 2 DG, as required in Schedule 6 of Cap. 295G. |
| 3.2.2.2 | It is important to note that the packing requirement of DG is independent from the licensing requirement of DG. Packing requirement regulates how the DG shall be packed, e.g. the size and material of the packaging, whilst licensing requirement refers to when a DG licence is required, e.g. quantity of DG exceeds EQ. Thus, packing requirement shall be observed for the storage or conveyance of DG independently from the licensing requirement of DG. |
| 3.2.2.3 | The requirements in this chapter should not be regarded as exhausting those matters which need to be covered by the relevant legal requirements. |
| 3.2.3 | Packing Requirements |
| 3.2.3.1 | Basic Packing Instructions (BP) |
| 3.2.3.1.1 | The appropriate Basic Packing Instruction (BP) and the Special Packing Instruction (SP) under the BP, if any, for the specific DG provided at column 7 of the DG List shall be met. Details of BP with SP are provided at Appendix 5 of the Code. |
| 3.2.3.1.2 | The BP provides the suitable type of packaging [i.e. combination packaging (inner packaging together with outer packaging), single packaging, composite packaging and cylinder (in BP209 only)] with details, including appropriate material, size limit and other requirements, for storage and conveyance of the respective DG. Under BP, SP is also specified for some DG which provides additional packing requirements for the specific DG. |
| 3.2.3.1.3 |
If combination packaging is suitable according to the corresponding BP of the DG, the individual use of an inner packaging (without the outer packaging of a combination packaging) is also considered as suitable during:
(a) conveyance of DG with each type of DG does not exceed their respective GEQ and the aggregate quantity of DG does not exceed the aggregate EQ; and (b) storage of DG. |
| 3.2.3.1.4 | Tanks licensed / approved by FSD are also suitable for storage of DG. |
| 3.2.3.2 | General Provisions |
| 3.2.3.2.1 | The packaging shall be strong enough to withstand the shocks and loadings normally encountered during normal conditions of handling. |
| 3.2.3.2.2 | No dangerous residue shall adhere to the outside of packaging. |
| 3.2.3.2.3 |
The interior surface of the packaging with which the DG may come into contact:
(a) shall not be affected or significantly weakened by those DG; (b) shall not cause a dangerous effect (e.g. catalysing a reaction or reacting with the DG); (c) shall not allow permeation of the DG that could constitute a danger under normal conditions of storage or conveyance; and (d) where necessary to comply with (a) to (c) above, they shall be provided with a suitable inner coating or treatment. |
| 3.2.3.2.4 | When DG are conveyed exceeding the GEQ or aggregate EQ, as the case may be, and combination packaging is used, the inner packagings shall be packed in the outer packaging in such a way that the inner packagings cannot break or leak their contents into the outer packaging or they cannot be punctured. Inner packagings that are susceptible to physical damage, such as those made of glass, porcelain or of certain plastic materials etc., shall be secured in outer packaging with suitable cushioning materials. The protective properties of the cushioning materials or of the outer packaging shall not be substantially impaired by any leakage of the contents. |
| 3.2.3.2.5 | Cushioning and absorbent materials used shall be inert and suited to the nature of the contents. |
| 3.2.3.2.6 | The nature and the thickness of the outer packagings shall be such that friction during conveyance does not generate any heating likely to alter dangerously the chemical stability of the contents. |
| 3.2.3.2.7 | Liquids shall be filled only into packagings which have appropriate resistances to the internal pressure that may develop under normal conditions of storage and conveyance. As the vapour pressure of low-boiling-point liquids is usually high, the strength of receptacles for these liquids shall be sufficient to withstand, with an ample factor of safety, the internal pressure likely to be generated. |
| 3.2.3.2.8 | Packagings for solids that may become liquid at temperatures likely to be encountered during storage and conveyance shall also be capable of containing the substances in the liquid state. |
| 3.2.3.2.9 | Packagings for powdery or granular substances shall be sift-proof or shall be provided with a liner. |
| 3.2.3.2.10 | The integrity of the packaging shall not be affected if ice is used as a coolant. |
| 3.2.3.2.11 | The table below listed all the suitable types of outer packagings of combination packagings, single packagings and composite packagings with the maximum capacity or maximum net mass for the DG with the Basic Packing Instructions of BP003, BP302, BP406, BP412, BP601, BP602 & BP804, when there is no maximum net mass or capacity specified in the BP. |
| Kind | Material | Category |
Maximum Capacity (L) |
Maximum Net Mass (kg) |
| Drums | Steel | Non-removable |
450
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400
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| Removable | ||||
| Aluminium | Non-removable | |||
| Removable | ||||
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Metal, other than steel or aluminium |
Non-removable | |||
| Removable | ||||
| Fibre | N.A. |
450
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| Plastics | Non-removable | |||
| Removable | ||||
| Plywood | N.A. |
250 |
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| Jerricans | Steel | Non-removable |
60
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120
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| Removable | ||||
| Aluminium | Non-removable | |||
| Removable | ||||
| Plastics | Non-removable | |||
| Removable | ||||
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| Boxes | Natural wood | Ordinary |
N.A.
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400
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| With sift-proof walls | ||||
| Plywood | N.A. | |||
| Reconstituted wood | N.A. | |||
| Fibreboard wood | N.A. | |||
| Plastics | Expanded plastics |
60 |
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| Solid plastics |
400 |
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Steel, Aluminium or other metal |
N.A. |
400 |
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| Bags |
Textile |
Without inner lining or coating |
N.A.
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50
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| Sift-proof | ||||
| Water-resistant | ||||
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Woven plastics |
Without inner lining or coating | |||
| Sift-proof | ||||
| Water-resistant | ||||
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Plastics film |
N.A. | |||
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Paper |
Multiwall |
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Multiwall, water-resistant |
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| Composite Packaging (Plastics material) | ||||
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Plastics receptacle with outer steel drum |
250
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400
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Plastics receptacle with outer aluminium drum |
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Plastics receptacle with outer plywood drum |
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Plastics receptacle with outer fibre drum |
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Plastics receptacle with outer plastics drum |
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Plastics receptacle with outer steel crate or box |
60
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75
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Plastics receptacle with outer aluminium crate or box |
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Plastics receptacle with outer wooden box |
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Plastics receptacle with outer plywood box |
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Plastics receptacle with outer fibreboard box |
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Plastics receptacle with outer solid plastics box |
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| Composite Packaging (Glass or Porcelain) | ||||
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Receptacle with outer steel drum |
60
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75
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Receptacle with outer steel crate or box |
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Receptacle with outer aluminium drum |
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Receptacle with outer aluminium crate or box |
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Receptacle with outer wooden box |
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Receptacle with outer plywood drum |
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Receptacle with outer wickerwork hamper |
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Receptacle with outer fibre drum |
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Receptacle with outer fibreboard box |
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Receptacle with outer expanded plastics packaging |
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Receptacle with outer solid plastics packaging |
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| 3.2.3.3 | Closure |
| 3.2.3.3.1 | The packaging shall be constructed and closed so as to prevent any loss of contents which may be caused under normal conditions of handling, by vibration, or by changes in temperature, humidity or pressure. The packaging shall be closed in accordance with the information provided by the manufacturer, if any. |
| 3.2.3.3.2 | The closures of packagings containing wetted or diluted substances shall be such that the percentage of liquid (water, solvent or phlegmatizer) does not fall below the prescribed limits, as stated in Cap. 295E and Chapter 2.2 of the Code, during storage and conveyance. |
| 3.2.3.3.3 |
Unless otherwise specified in the BP, packages containing following DG shall be hermetically sealed:
(a) evolve flammable gases or vapour; (b) may become explosive if allowed to dry; (c) evolve toxic gases or vapour; (d) evolve corrosive gases or vapour; or (e) may react dangerously with the atmosphere. |
| 3.2.3.4 | Vent |
| 3.2.3.4.1 | A venting device shall be fitted if dangerous overpressure may develop due to normal decomposition of substances or the emission of gas from the contents (as a result of temperature increase or other causes) provided that the gas emitted will not cause danger on account of its toxicity, its flammability, the quantity released, etc. The vent shall be so designed that leakages of liquid and the penetration of foreign substances are prevented under normal conditions of handling. |
| 3.2.3.5 | Filling |
| 3.2.3.5.1 | Packaging being filled shall be maintained in good condition and repair and free from corrosion, contamination or other defects. |
| 3.2.3.5.2 |
When filling packagings with liquids, sufficient ullage shall be left to ensure that neither leakage nor permanent distortion of the packaging occurs as a result of an expansion of the liquid caused by temperatures. For a filling temperature of 15°C, the minimum ullage shall be determined as follows, unless otherwise provided in BP:
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| 3.2.3.6 |
Mixed Packing Provisions |
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| 3.2.3.6.1 |
Multiple types of DG shall not be packed together if they are determined as incompatible according to 2.3.3 of the Code, except for the following situations:
(a) during storage, each type of DG does not exceed their respective GEQ / IEQ / SEQ (as the case may be) and the aggregate quantity of DG does not exceed the aggregate EQ; or (b) during conveyance, each type of DG does not exceed their respective GEQ and the aggregate quantity of DG does not exceed the aggregate EQ. |
| 3.2.3.6.2 |
In principle, DG shall not be packed together in the same outer packaging with other DG or other goods which may react dangerously with each other and cause:
(a) combustion and / or evolution of considerable heat; (b) evolution of flammable, toxic or asphyxiant gases; (c) formation of corrosive substances; or (d) formation of unstable substances. |